Prospect Data Notice and Data Removal Policy

Mediacle Limited — MARS™ affiliate directory

Version 1.0 — Last updated: 4 August 2026

Why you are reading this

If you own or work on an affiliate, publisher, review or comparison website in the iGaming sector, your business contact details may appear in the MARS™ directory. You did not give those details to us — we collected them from publicly available sources.

UK and EU data protection law requires us to tell you what we hold, why we hold it, and what you can do about it. That is what this notice does.

If you simply want to be removed, go straight to section 9, or use our removal form: https://mars.mediacle.com/data-removal

We do not require a reason, we do not charge, and we do not ask you to justify the request.

1. Who we are

Mediacle Limited is the controller of the personal data described in this notice. We decide what data goes into the MARS™ directory and why.

EU Representative (Article 27 EU GDPR):

Chris K

Box no. 16416

103 27 Stockholm

Sweden

2. What MARS™ is

MARS™ is a business-to-business software platform used by licensed iGaming operators and their marketing teams. It helps them identify affiliate and publisher websites that might be suitable partners, and contact the people responsible for those websites to propose a commercial partnership.

We are not a marketing list broker. We do not sell data. Our customers pay for access to the platform, not for copies of a database.

3. What personal data we hold

We hold business contact information relating to your professional role, which may include:

• your name;
• your job title or role;
• your business email address;
• your business telephone number;
• links to your publicly visible professional social profiles, for example LinkedIn, X or Telegram;
• the website or websites you are associated with, and the domain's public contact page details;
• publicly observable information about those websites — estimated traffic and rankings, keywords, the brands the site promotes, geographic focus, vertical, and quality or authority scores we calculate ourselves;
• where you have previously corresponded with a MARS™ customer through the platform, the fact of that correspondence and its status.

We do not hold special category data — nothing about your health, ethnicity, religion, politics, sex life, sexual orientation, trade union membership, genetics or biometrics. We do not hold criminal offence data. We do not hold personal financial information, and we do not hold data about your private life.

Some of what we hold is inferred or estimated rather than observed. Scores, traffic figures, categorisations and the association between a person and a website are our best assessment and may be wrong.

4. Where we got it

We collect from publicly accessible sources only:

• Public websites — contact, about, advertising, partnership and imprint pages, and structured data published on those pages;
• Public search engine results and publicly accessible web indexes;
• Publicly visible social media and professional networking profiles;
• Publicly available business directories and industry listings;
• Hunter.io, a third-party business contact discovery and verification provider based in France, which sources business email addresses from publicly available web pages;
• Direct correspondence, where you have replied to a message sent through MARS™ or contacted us.

We do not buy consumer marketing lists, we do not scrape data from behind logins or paywalls, and we do not use data obtained in breach of any website's terms.

5. Why we process it, and our lawful basis

Our lawful basis is legitimate interests under Article 6(1)(f) UK GDPR and EU GDPR. Our purposes are:

1. to compile and maintain a directory of iGaming affiliate and publisher websites and the business contacts responsible for them;
2. to verify and keep that information accurate and current;
3. to make it available to our business customers so they can identify and evaluate potential affiliate partners;
4. to enable our customers to send business-to-business partnership proposals to those contacts from the customer's own email address;
5. to operate suppression and opt-out mechanisms; and
6. to analyse market structure, for example which affiliates promote which brands.

Our legitimate interests assessment, in summary. Our interest is in operating a lawful B2B partner-discovery service. The processing is necessary because affiliate recruitment cannot function without knowing who runs a site and how to reach them, and no less intrusive method achieves it. On balance: the data relates to your professional role and is drawn from information you or your business have chosen to publish, often specifically so that partners can make contact; the volume of data about any one person is small; there is no profiling of you as an individual, only of the website; there are no legal or similarly significant automated decisions about you; the expected outcome is a business proposal you are free to ignore; and we operate an unconditional, permanent and free opt-out. We consider that our interests are not overridden by your interests, rights and freedoms — but if you disagree, section 9 tells you how to say so, and we will act on it.

You can request a fuller copy of our legitimate interests assessment by emailing mars@mediacle.com.

6. Who receives your data

• Our customers — licensed iGaming operators, affiliate managers and their agencies who subscribe to MARS™. They see your details inside the platform. They are contractually required to use them only for affiliate recruitment, to comply with data protection and electronic marketing law, to identify themselves in every message, to include a working opt-out, and to honour opt-outs permanently.
• Our service providers — Amazon Web Services (hosting and email delivery), Hunter.io (verification), OpenAI and Anthropic (AI-assisted analysis and drafting), Maxdesk.ai (support). None of them uses your data for their own purposes, and none is permitted to train AI models on it.
• Professional advisers, regulators, law enforcement and courts — where legally required or necessary to protect our rights.

We do not sell your personal data. Our customers cannot bulk-export the directory, and are contractually prohibited from reselling, re-licensing or building competing datasets from it.

Important: once one of our customers contacts you, that customer becomes an independent controller of your data for its own purposes. Removing yourself from our directory stops us providing your details and stops future contact through our platform, but we cannot delete data already held in a customer's own separate systems. If you want that deleted too, contact the sender directly — and tell us, and we will pass your request to the customer concerned.

7. Who sends you emails

Messages you receive are sent by our customers, from their own email addresses, using MARS™ as the tool. Our customer decides whether to contact you, what to say and how often. Our customer is the sender and is responsible under electronic marketing law for that message.

Every message must identify the sender and provide a way to opt out. If you receive a message through MARS™ that does not, or that continues after you have opted out, please forward it to mars@mediacle.com — we treat that as a serious breach of our Terms and we act on it, including by suspending the customer's account.

8. International transfers and retention

Transfers. Your data may be processed outside the UK and EEA, principally in the United States, because of the providers listed in section 6. Where we transfer data to a country without UK adequacy regulations we use the UK International Data Transfer Agreement, or the EU Standard Contractual Clauses with the UK Addendum, supported by a transfer risk assessment. You can request a copy of the safeguard by emailing us.

Retention.

9. Your rights, and how to be removed

You have the right to:

• object to our processing, which for direct-marketing-related purposes is an absolute right we will always honour;
• access the personal data we hold about you;
• have inaccurate data corrected;
• have your data erased;
• restrict our processing;
• receive your data in a portable format in certain circumstances;
• complain to a supervisory authority.

The fastest route: our removal form

https://mars.mediacle.com/data-removal

You will need to give the email address or domain you want removed. We may ask for a simple verification step to make sure the request is genuine and to prevent someone removing a colleague without authority.

Or email mars@mediacle.com with the subject line "Data removal request".

What we do when you ask to be removed

1. We remove your contact details from the MARS™ directory so no customer can see or use them.
2. We add you to a permanent suppression list, so that our crawlers and verification processes will not re-add you if your details appear publicly again in future.
3. We block outbound sending to your address through our platform.
4. We notify customers who have your record in their workspace that you have opted out and that they must not contact you again.
5. We confirm to you when this is done.

Timescale: we act on removal requests within 7 days wherever possible, and in all cases within one month, as required by law. Complex requests may be extended by up to two further months, and we will tell you if that happens.

Cost: free.

Complaints

If you are not happy with how we handle your request, tell us at mars@mediacle.com so we can put it right. You can also complain to:

United Kingdom — Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF · 0303 123 1113 · ico.org.uk

EEA — your local supervisory authority, or contact our EU Representative in section 1.

10. Changes to this notice

We may update this notice. The current version is always published at https://mars.mediacle.com/prospect-data with the date at the top.

Mediacle Limited · Registered in England and Wales No. 08757407 · VAT No. GB178524870 16 Upper Woburn Place, London, WC1H 0BS, United Kingdom · mars@mediacle.com